NOTICE OF DISCIPLINARY ACTION

MEMBER:

CREDIT SUISSE INTERNATIONAL

EXCHANGE RULE: 562. POSITION LIMIT VIOLATIONS

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement Credit Suisse International (“CSI”) presented at a hearing on January 29, 2019, in which CSI neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that on the morning of May 30, 2018, the Exchange notified CSI that it held a futures-equivalent short position of 239 NYMEX June 2018 Palladium futures (“JUN18 PA”) contracts and that the position limit of 50 JUN18 PA contracts would be going into effect at the close of business on May 30, 2018. Despite such notice, CSI did not reduce its position below the applicable limit by the close of business on May 30, 2018 and therefore exceeded the position limit in the JUN18 PA contract by 189 contracts, or 378%.

The Panel found that as a result, CSI violated Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered CSI to pay a fine to the Exchange in the amount of $95,000.